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NO. 43444 -0 -II
IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON
DIVISION TWO
STATE OF WASHINGTON,
Respondent,
V.
MICHAEL D. COLLINS, II,
Appellant.
ON APPEAL FROM THE SUPERIOR COURT OF THE
STATE OF WASHINGTON FOR SKAMANIA COUNTY
The Honorable Brian Altman, Judge
BRIEF OF APPELLANT
LISA E. TABBUT
Attorney for AppellantP. O. Box 1396
Longview, WA 98632360) 425 -8155
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TABLE OF CONTENTS
Page
A. ASSIGNMENTS OF ERROR ........................... ..............................1
1. The trial court deprived Mr. Collins an open trial by unilaterallysealing the jury questionnaire used during voir dire without consentof the parties or weighing the Bone -Club factors . ..............................1
2. Mr. Collins's Skamania County conviction put him in jeopardyin violation of the Double Jeopardy Clause .......... ..............................1
3. The trial court misapplied the law as to double jeopardy when itrefused to grant Mr. Collins' pre -trial motion to dismiss forviolating the Double Jeopardy Clause .................. ..............................1
4. The trial court had no legal authority to enter a judgmentagainst Mr. Collins for failure to register as a sex offender .............. 1
B. ISSUES PERTAINING TO ASSIGNMENTS OF ERROR .........1
1. During voir dire, the court used a jury questionnaire todetermine whether the prospective jurors knew Mr. Collins andhow they knew him. The day after the jury reached its verdict, thecourt entered an order sealing the jury questionnaire. The parties,including Mr. Collins, did not agree to seal the questionnaire andthe court did not engage in a Bone -Club analysis before signing theorder to seal. Is Mr. Collins's entitled to have his case remanded
for a Bone -Club analysis? 1
2. The Double Jeopardy Clause protects against successiveprosecutions for the same offense. Mr. Collins was convicted in2009 for failing to register as a sex offender in Clark County fromJanuary 1, 2009, to March 4, 2009. In 2011, he was convicted forfailure to register as a sex offender in Skamania County fromFebruary 4 -9, 2009. Was the Double Jeopardy Clause violatedwhen the jury was permitted to find Mr. Collins guilty in SkamaniaCounty for an offense for which he had already been convicted inClarkCounty? ........................................................ ............................... 2
Appellant's Brief - i
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C. STATEMENT OF THE CASE AND PRIOR PROCEEDINGS.. 2
1. Mr. Collins was convicted in Skamania County of attemptedfirst degree murder and first degree robbery ..... ............................... 2
2. Mr. Collins attempted first degree murder conviction wasreversedon appeal ................................................. ............................... 3
3. Skamania County filed a new failure to register charge againstMr. Collins alleging incident dates for which Mr. Collins wasalready charged and convicted in Clark County ............................... 3
4. The court refused to dismiss Mr. Collins' new charges asviolating double jeopardy ...................................... ............................... 4
5. The trial court sealed a jury questionnaire used in voir dire...... 5
6. Mr. Collins is found guilty of failure to register as a sex offenderinSkamania County .............................................. ............................... 6
D. ARGUMENT... 8
1. THE SEALING OF THE JURY QUESTIONNAIRENECESSITATES REMAND OF MR. COLLINS CASE FOR A
BONE -CLUB ANALYSIS ..................................... ............................... 8
2. MR. COLLINS WAS PUT IN JEOPARDY TWICE FORFAILING TO REGISTER AS A SEX OFFENDER IN TWO
COUNTIES ON OVERLAPPING DATES IN VIOLATION OF
THE DOUBLE JEOPARDY CLAUSE ............... .............................10
a. The Double Jeopardy clause precluded the State fromprosecuting Mr. Collins in Skamania County for the sameincidents underlying the Clark County convictions.
11
b. Mr. Collins was prosecuted twice for the continuing offenseof failing to register as a sex offender between January 1, 2009,andMarch 4, 2009 .............................................. .............................12
E. CONCLUSION .................................................. .............................14
Appellant's Brief - ii
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CERTIFICATE OF SERVICE ................................ .............................16
Appellant's Brief - iii
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TABLE OF AUTHORITIES
Page
Cases
Benton v. Maryland, 395 U.S. 784, 89 S.Ct. 2056, 23 L.Ed.2d707 (1969)11
In re Barr, 102 Wn.2d 265, 684 P.2d 712 ( 1984 ) ............................. 3, 4, 10
North Carolina v. Pearce, 395 U.S. 711, 89 S.Ct. 2072, 23 L.Ed.2d 656
1969), overruled on other grounds by Alabama v. Smith, 490 U.S. 794,109 S.Ct. 2201, 104 L.Ed. 2d 865 ( 1989) .............. ............................... 11
State v. Beskurt, 159 Wn. App. 819, 246 P.3d 580, review granted, 172Wn.2d 1013 (2011) ........................................ ............................... 8, 9, 10
State v. Bone -Club, 128 Wn.2d 254, 906 P.2d 325 ( 1995 ) ...........................
i, ii, 1, 6, 8, 9, 10, 15
State v. Chouap, 170 Wn. App. 114, 285 P.3d 138 (2012) ................... 9,10
State v. Collins (unpublished opinion), 162 Wn.2d 1051, P.3d __, WL2848819 ( 2011) ........................................................ ............................... 3
State v. Dent, 123 Wn.2d 467, 869 P.2d 392 (1994) . ............................... 13
State v. Durrett, 150 Wn. App. 402, 208 P.3d 1174 (2009) ..................... 12
State v. Gocken, 127 Wn.2d 95, 896 P.2d 1267 ( 1995 ) ............................ 11
State v. Green, 156 Wn. App. 96, 101, 230 P.3d 654 (2010) ................... 12
State v. Hughes, 166 Wn.2d 675, 212 P.3d 558 ( 2009 ) ............................ 11
State v. Noltie, 116 Wn.2d 831, 809 P.2d 190 (1991) .............................. 11
State v. Peterson, 168 Wn.2d 763, 230 P.3d 588 ( 2010) .......................... 12
Appellant's Brief - iv
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Statutes
RCW9A.04. 030 ......................................................... ............................... 13
RCW 9A..44.130 ( 2009) ...................................... ............................... 10,13
RCW9A.44. 130 ......................................................... ............................... 14
RCW 9.94A. 505( 2)( B) ............................. ..............................3
Other Authorities
CrR5. 1( a)( 2) ................................................ ...............................
U.S. Const. Amend 5 ................................... ...............................
13
11
Appellant's Brief - v
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A. ASSIGNMENTS OF ERROR
1. The trial court deprived Mr. Collins an open trial by unilaterally
sealing the jury questionnaire used during voir dire without consent of the
parties or weighing the Bone -Club factors.
2. Mr. Collins's Skamania County conviction put him in jeopardy
in violation of the Double Jeopardy Clause.
3. The trial court misapplied the law as to double jeopardy when it
refused to grant Mr. Collins' pre -trial motion to dismiss for violating the
Double Jeopardy Clause.
4. The trial court had no legal authority to enter a judgment
against Mr. Collins for failure to register as a sex offender.
B. ISSUES PERTAINING TO ASSIGNMENTS OF ERROR
1. During voir dire, the court used a jury questionnaire to
determine whether the prospective jurors knew Mr. Collins and how they
knew him. The day after the jury reached its verdict, the court entered an
order sealing the jury questionnaire. The parties, including Mr. Collins,
did not agree to seal the questionnaire and the court did not engage in a
Bone -Club analysis before signing the order to seal. Is Mr. Collins's
entitled to have his case remanded for a Bone -Club analysis?
2. The Double Jeopardy Clause protects against successive
prosecutions for the same offense. Mr. Collins was convicted in 2009 for
Appellant's Brief - 1
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failing to register as a sex offender in Clark County from January 1, 2009,
to March 4, 2009. In 2011, he was convicted for failure to register as a
sex offender in Skamania County from February 4 -9, 2009. Was the
Double Jeopardy Clause violated when the jury was permitted to find Mr.
Collins guilty in Skamania County for an offense for which he had already
been convicted in Clark County?
C. STATEMENT OF THE CASE AND PRIOR PROCEEDINGS
1. Mr. Collins was convicted in Skamania County ofattempted first degree murder and first degree robbery.
In 2009, Michael Collins was charged and convicted by a
Skamania County jury of attempted murder in the first degree and robbery
in the first degree. Post - sentencing, Mr. Collins filed a notice of appeal.
CP 22 -35.
From there, Mr. Collins was taken to Clark County to face charges
of custodial interference and failure to register as a sex offender. CP 3.
Later, the custodial interference was dismissed and Mr. Collins entered
into a plea agreement on the failure to register charge. CP 3. Although the
failure to register occurred between January 1 and March 4, 2009, the
State agreed to amend the charge to reflect it having occurred in 2006. CP
13 -15; RP1 at 3 -6. Supplemental Statement of Arrangements Exhibits 4
and 5 filed December 15, 2011 and Exhibits 1, 2, and 3 filed January 5,
Appellant's Brief - 2
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2012. The purpose of the amendment was to take advantage at sentencing
of failure to register's former sentencing guideline classification as an
unranked felony offense with a standard range of 0 -12 months. RP at 17;
RCW9.94A.505(2)(b).
Mr. Collins entered an In re Barr plea, a legal fiction that allowed
him to enter a guilty plea not otherwise supported by the facts. In re Barr,
102 Wn.2d 265, 684 P.2d 712 (1984); RP1 at 7 -8.
2. Mr. Collins attempted first degree murder convictionwas reversed on appeal.
In an unpublished opinion, this Court reversed Mr. Collins'
attempted first degree murder conviction and affirmed the robbery
conviction. State v. Collins (unpublished opinion), 162 Wn.2d 1051,
P.3d , WL 2848819 (2011); CP 22 -35. On remand, the attempted
murder conviction was dismissed and Mr. Collins was resentenced on the
first degree robbery. CP 3 -4. Mr. Collins returned to the Department of
Corrections to complete his sentence. CP 4.
3. Skamania County filed a new failure to registercharge against Mr. Collins alleging incident dates forwhich Mr. Collins was already charged and
convicted in Clark County.
However, within a few months, the State brought Mr. Collins back
to Skamania County to face a new failure to register as a sex offender
charge. CP 4. The alleged dates of the crime occurred within the January
Appellant's Brief - 3
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I- March 4, 2009, dates charged in Clark County for the same crime. CP
13 -15, 118 -19; RP 2B at 283, 291, 318 -21; Supplemental Statement of
Arrangements, Exhibits 4 and 5 filed December 15, 2011 and Exhibits 1,
2, and 3 filed January 5, 2012. Specifically, Skamania County charged
Mr. Collins with having failed to register in Skamania County between
February 4 -9, 2009. CP 118 -19.
4. The court refused to dismiss Mr. Collins' new
charges as violating double jeopardy.
Mr. Collins moved to dismiss the new failure to register charge on
various grounds to include that it violated double jeopardy. CP 1 -36; RP1
at 1 -33. Mr. Collins argued he had already been convicted and sentencing
by the State of Washington, specifically Clark County, for having failed to
register as a sex offender for the February 2009 window of time Skamania
County alleged in its new charge. RP1 at 1 -24; CP 1 -36.
At the dismissal motion, the court understood and accepted the
legal fiction of the In re Barr plea which took the Clark County failure to
register charges back to 2006. RP1 at 19. The court acknowledged the
failure to register behavior in Clark County actually occurred between
January 1 and March 4, 2009. RP1 at 19. But the court refused to grant
the dismissal motion believing instead that Skamania County had an
independent right to prosecute Mr. Collins for failure to register even
Appellant's Brief - 4
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though Clark County convicted Mr. Collins for the same offense occurring
during the same window of time. RP 20 -22; Supplemental Statement of
Arrangements, Exhibits 4 and 5 filed December 15, 2011 and Exhibits 1,
2, and 3 filed January 5, 2012.
5. The trial court sealed a jury questionnaire used in voirdire.
At the request of counsel, the court used a jury questionnaire in
voir dire. RP1 at 107 -119. The questionnaire was used to determine what
each prospective juror knew, if anything, about Mr. Collins. The
prospective jurors filled out the questionnaire prior to general voir dire
questioning by the court and the attorneys. The attorneys used the filled
out questionnaires during voir dire. Nothing in the record suggests that
the public was excluded from the courtroom during voir dire. RP2A at
152 -248.
The day after the jury returned its verdict, the court entered an
order sealing the jury questionnaire. Supplemental Designation of Clerk
Papers, Order Sealing Document (sub. nom. 76). The sealing order is a
pre - printed form that allows the court to fill in certain information such as
naming the item sealed, here "Juror Questionnaires." The stated purpose
for having the form sealed is boilerplate: "[S]aid document contains
specific and sensitive information that should remain confidential."
Appellant's Brief - 5
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Supplemental Designation of Clerk Papers, Order Sealing Document (sub.
nom. 76).
None of the parties, and certainly not Mr. Collins, signed the
sealing order. No information in the record suggests that the court
engaged in a Bone -Club analysis before sealing the jury questionnaire.
Supplemental Designation of Clerk Papers, Order Sealing Document (sub.
nom. 76).
6. Mr. Collins is found guilty of failure to register as a sexoffender in Skamania County.
The evidence at trial established that Mr. Collins was required to
register as a sex offender based on a Clark County sex offense conviction.
RP3 at 433, 467. In 2008, Mr. Collins registered with the Clark County
Sheriff's Office as having a fixed address in Vancouver, Washington.
RP3 at 436. In late December 2008, Mr. Collins mother appeared at the
Clark County Sheriff's Office with a note from Mr. Collins witnessed by
her. The note explained that Mr. Collins was leaving the state. The note
did not give any information about which state he was moving to or
otherwise give an address where Mr. Collins could be contacted. Clark
County Sheriff's Detective Kevin McVicker, who was charged with
handling sex offender registration for Clark County, testified that the note
was not a legal method to change a sex offender address. RP3 at 437 -45.
Appellant's Brief - 6
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On February 3 or 4, 2009, friends dropped Mr. Collins and his son,
Teven Collins, at the Dougan Falls Campground in Skamania County. RP
2B at 317 -18. The two planned to lay low at the campground for some
time. RP 2B at 282 -83, 319, 321. They brought some food, extra
clothing, and a blanket with them. RP2B at 325, Over the next few days,
they moved from campsite to campsite. RP2B at 300. They were last
seen at the campground on February 9, 2009. RP 2B at 361.
During his stay at the campground, Mr. Collins never went to the
Skamania County Sheriff's Office to report his presence at the
campground. RP2B at 397 -98.
The jury found Mr. Collins guilty of failing to register as a sex
offender in Skamania County. CP 120. Post - conviction, the court again
refused to dismiss Mr. Collins' conviction for violating double jeopardy.
The court sentenced Mr. Collins to 57 months to run consecutive to his
2009 first degree robbery. CP 126. Mr. Collins now appeals his
conviction. CP 141 -62.
Appellant's Brief - 7
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D. ARGUMENT
1. THE SEALING OF THE JURY QUESTIONNAIRENECESSITATES REMAND OF MR. COLLINS CASE
FOR A BONE -CLUB ANALYSIS.
Divisions One and Two of this Court have reached contrary results
on this issue.
In Division One, in State v. Beskurt, as in Mr. Collins' case, the
parties stipulated and the court agreed that the members of the venire
would complete a confidential jury questionnaire. After the answers were
made available to counsel, they questioned the members of the venire in
open court. Thereafter, all parties selected and accepted the jury as
constituted. Following the selection, acceptance, and swearing of the jury,
the court entered an order sealing the completed jury questionnaires. State
v. Beskurt, 159 Wn. App. 819, 824, 246 P.3d 580, review granted, 172
Wn. 2d 1013 (2011).
The defendant appealed claiming the trial judge violated his right
to an " open and public" trial by sealing the preliminary juror
questionnaires without first conducting a Bone —Club analysis on the
record. Beskurt, 159 Wn. App. at 824; State v. Bone -Club, 128 Wn.2d
254, 906 P.2d 325 (1995). The court held there was no violation of his
right to a public trial. But the trial court's failure to conduct a Bone —Club
hearing before sealing the questionnaires is inconsistent with the public's
Appellant's Brief - 8
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right of open access to court records. A Bone -Club analysis requires the
court to weigh the following five factors.
1. The proponent of closure or sealing must make some showing ofa compelling interest, and where that need is based on a right otherthan an accused's right to a fair trial, the proponent must show aserious and imminent threat' to that right.
2. Anyone present when the closure motion is made must be givenan opportunity to object to the closure.
3. The proposed method for curtailing open access must be theleast restrictive means available for protecting the threatenedinterests.
4. The court must weigh the competing interests of the proponentof closure and the public.
5. The order must be no broader in its application or duration thannecessary to serve its purpose."
Bone -Club, 128 Wn.2d at 258 -59.
As a remedy, the court ordered the case remanded for the trial
court to conduct a Bone —Club hearing and to reconsider its closing order.
Beskurt, 159 Wn.App. at 834. As noted above, the Supreme Court granted
review of Beskurt. See Supreme Court No. 85737 -3.
This Court reached a contrary result. State v. Chouap, 170 Wn.
App. 114, 129, 285 P.3d 138 (2012). In so doing, this Court reasoned,
After the trial was over, the trial judge ordered the juryquestionnaires sealed and both parties agreed to the order. There isno evidence that jury selection did not proceed in open court. Noris there any evidence that the court denied either party, or any
1 Oral argument was heard on February 16, 2012
Appellant's Brief - 9
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member of the public, access to the questionnaires. Chouap agreedto use and did use the juror questionnaires to question prospectivejurors.
Chouap, 170 Wn. App. at 129.
A petition for review has been filed in Chouap. (See Supreme
Court No. 87887 -1.) Consideration on the Petition for Review is set for
February 5, 2013.
Mr. Collins asks this Court to adopt the reasoning of Beskurt and
remand his case to the trial court for a Bone -Club analysis.
2. MR. COLLINS WAS PUT IN JEOPARDY TWICEFOR FAILING TO REGISTER AS A SEX
OFFENDER IN TWO COUNTIES ON
OVERLAPPING DATES IN VIOLATION OF THE
DOUBLE JEOPARDY CLAUSE.
In 2009, Mr. Collins pleaded guilty under In re Barr in Clark
County to failure to register as a sex offender. RCW 9A.44.130 (2009).
Two years later, the Skamania County prosecutor filled an information
charging Mr. Collins with failure to register in Skamania County based on
the same allegations Mr. Collins pleaded guilty two years earlier in Clark
County. Despite Mr. Collins' well- reasoned argument that the Skamania
County charge constituted double jeopardy, the trial court allowed a jury
to consider the evidence. After the jury found Mr. Collins guilty as
charged, the court entered a judgment of guilt. Mr. Collins was therefore
Appellant's Brief - 10
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prosecuted twice for the Clark County incident in violation of the Double
Jeopardy Clause. His conviction must be vacated.
a. The Double Jeopardy clause precluded the Statefrom prosecuting Mr. Collins in Skamania
County for the same incidents underlying theClark County convictions.
The Double Jeopardy Clause of the Fifth Amendment "protects
against a second prosecution for the same offense after conviction." North
Carolina v. Pearce, 395 U.S. 711, 717, 89 S.Ct. 2072, 23 L.Ed.2d 656
1969), overruled on other grounds by Alabama v. Smith, 490 U.S. 794,
109 S.Ct. 2201, 104 L.Ed. 2d 865 (1989); U.S. Const. Amend 5 ( "Nor
shall any person be subject for the same offense to be twice in jeopardy of
life and limb. ") The clause applies to the states through the Fourteenth
Amendment. Benton v. Maryland, 395 U.S. 784, 787, 89 S.Ct. 2056, 23
L.Ed.2d 707 (1969). The state constitutional prohibition against double
jeopardy offers the same scope of protection as its federal counterpart.
State v. Gocken, 127 Wn.2d 95, 107, 896 P.2d 1267 (1995); Const. Art. 1
9 ( "No person shall ... be twice out in jeopardy for the same offense. ")
A double jeopardy violation is reviewed de novo. State v. Hughes,
166 Wn.2d 675, 681, 212 P.3d 558 (2009). In reviewing an allegation of
double jeopardy, the appellate court reviews the entire record. State v.
Noltie, 116 Wn.2d 831, 848 -49, 809 P.2d 190 (1991).
Appellant's Brief - 11
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b. Mr. Collins was prosecuted twice for the
continuing offense of failing to register as a sexoffender between January 1, 2009, and March 4,2009.
Failure to register as a sex offender is a not an alternative means
offense. State v. Peterson, 168 Wn.2d 763, 770, 230 P.3d 588 (2010). The
failure to register statute contemplates a single act that amounts to failure
to register: the offender moves without alerting the appropriate authority.
Id. The conduct is the same. The offender moves without notice or he
does not. The fact that different statutory deadlines may apply, depending
on the offender's residential status, does not change the nature of the
criminal act: moving without registering. Id. The unit of prosecution for
failure to register as a sex offender is the ongoing duty to report rather
than each separate duty to report. State v. Green, 156 Wn. App. 96, 101,
230 P.3d 654 (2010); State v. Durrett, 150 Wn. App. 402, 410, 208 P.3d
1174 (2009).
And that is what Mr. Collins argued at the motion to dismiss. In
2011, Skamania County charged Mr. Collins with being an unregistered
sex offender in their county for five days, from February 4 -9, 2009. But
Mr. Collins had already pled guilty and been sentenced in Clark County
for failure to register for a time period encompassing January 1, 2009, to
March 4, 2009. In denying Mr. Collins motion to dismiss, the court
Appellant's Brief - 12
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wrongly accepted the prosecutor's argument that Skamania County, as its
own political entity with its own prosecutor, had a right to prosecute and
punish Mr. Collins separately from Clark County.
In reality, the jurisdiction for prosecution and punishment lies with
the State of Washington. RCW 9A.04.030. The venue is not an element
of the crime. State v. Dent, 123 Wn.2d 467, 479, 869 P.2d 392 (1994).
Under CrR 5.1(a)(2), a criminal action may be commenced in any county
where an element of the offense was committed or occurred.
Here, as instructed in the to- convict instruction, both elements (4)
and (5) occurred in Clark Country.
To convict the defendant of the crime of Failure to Register as aSex Offender, each of the following elements of the crime must beproved beyond a reasonable doubt:
1) That on or between February 4, 2009 through February 9, 2009,the defendant knowingly failed to register with the SkamaniaCounty Sheriff not more then twenty -four hours after enteringSkamania County;
2) That the defendant remained within Skamania County for twenty -four hours after entering Skamania County;
3) That the defendant lacked a fixed residence at the time;
4) That the defendant had previously registered with the Clark CountSheriff;
5) That the defendant had previously been convicted of a sex offensethat would be classified as a felony under the law of Washingtonand was required to register pursuant to RCW 9A.44.130; and
Appellant's Brief - 13
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6) That he acts occurred in the State of Washington.
Supplemental Statement of Arrangements, Court's Instructions to the Jury,
Instruction 7 (sub. nom. 71).
To prove the Clark County specific elements, the prosecutor called
Clark County Sheriff's Detective Kevin McVicker as a witness. Detective
McVicker testified that Mr. Collins had to register as sex offender in
Washington. Mr. Collins had done so with the Clark County Sheriff's
Office in December 2008. Mr. Collins provided a residential address in
Vancouver. Mr. Collins was given notice under RCW 9A.44.130 of his
registration requirements. And on December 29, 2008, Mr. Collins mother
came into the Sheriff's Office with a handwritten note from Mr. Collins
saying he was moving out of state. RP3 at 433 -38.
The trial court erred when it failed to recognize both the unit of
prosecution for failure to register and the ability to prosecute a violation of
state law in any county where at least one element occurred.
Mr. Collins' Skamania County conviction for failure to register as
a sex offender should be reversed because it violates double jeopardy.
E. CONCLUSION
Mr. Collins' Skamania County conviction for failure to register as
a sex offender violates double jeopardy and should be remanded with
instructions to dismiss. Alternatively, Mr. Collins' case should be
Appellant's Brief - 14
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remanded to the trial court to analyze sealing of the jury questioners under
State v. Bone -Club.
Respectfully submitted this 12th day of December 2012.
LISA E. TABBUT/WSBA #21344
Attorney for Michael D. Collins, II
Appellant's Brief - 15
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CERTIFICATE OF SERVICE
Lisa E. Tabbut declares as follows:
On today's date, I efiled Appellant's Brief to: (1) Adam Kick, SkamaniaCounty Prosecutor's Office, at [email protected]; (2) the Court ofAppeals, Division II; and (3) I mailed it to Michael D. Collins, II,DOC #805173, Washington State Penitentiary, 1313 N. 13"' Ave.,Walla Walla, WA 99362
I CERTIFY UNDER PENALTY OF PERJURY UNDER THE LAWS OF
THE STATE OF WASHINGTON THAT THE FOREGOING IS TRUE
AND CORRECT.
Signed December 12, 2012, in Longview, Washington.
Lisa E. Tabbut, WSBA No. 21344
Attorney for Michael D. Collins, II
Appellant's Brief - 16
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COWLITZ COUNTY ASSIGNED COUNSEL
December 12, 2012 - 4:48 PMTransmittal Letter
Document Uploaded: 434440 - Appellant's Brief.pdf
Case Name: State v. Michael D. Collins, II
Court of Appeals Case Number: 43444 -0
Is this a Personal Restraint Petition? '; Yes No
The document being Filed is:
Designation of Clerk's Papers Supplemental Designation of Clerk's Papers
Statement of Arrangements
Motion:
Answer /Reply to Motion:
Brief: Appellant's
Statement of Additional Authorities
Cost Bill
Objection to Cost Bill
Affidavit
Letter
Copy of Verbatim Report of Proceedings - No. of Volumes:
Hearing Date(s):
Personal Restraint Petition (PRP)
Response to Personal Restraint Petition
Reply to Response to Personal Restraint Petition
Petition for Review (PRV)
Other:zs
Comments:
No Comments were entered.
Sender Name: Lisa E Tabbut - Email: IisaotalSlSatCcoaacast.et
A copy of this document has been emailed to the following addresses: